I am reading things that give me some different ways to look at when a part time employee has to be offered health insurance so I need some clarification. We employee over 100 employees of which 40 to 50 are full time. I have two part time employees who have averaged 33+ hours over the last three months. Do we have to offer them health insurance at this time or can you average the employees hours over a quarter?
Under the ACA employers can use look-back periods of between 3 and 12 months. If an employee works more than 30 hours a week over a 120 day period, or at least 130 hours a month, they are considered full-time. An employer can count actual hours worked, days-worked equivalency, or weeks-worked equivalency. The fee for not getting it right is a per-month, per-employee fee.
The above applies to determining full-time status for the fee. The calculation for the requirement to provide coverage is simpler and revolves around counting full-time equivalent employees (and reasonable accreditation of employee hours).
For further details see IRS QA on look-back periods under the ACA and IRS reasonable methods for crediting hours.